Five-Year Review Report for the Aberdeen Area, Aberdeen Proving Ground, Maryland September 2003 Prepared by Directorate of Safety, Health, and Environment Environmental Conservation and Restoration Division Aberdeen Proving Ground, Maryland ENVIRONMENTAL PROTECTION AGENCY REGION III 1650 Arch Street Philadelphia, Pennsylvania 19103 October 21,2003 Colonel Mardi U. Mark Commander, US Army Garrison (AMSSB-GCO) 2201 Aberdeen Boulevard Aberdeen Proving Ground, Maryland 21005-5001 RE: Five-Year Review for the Aberdeen Proving Ground - Aberdeen Area Dear Mr. Stachiw: The U.S. Environmental Protection Agency (EPA) Region III has reviewed the report entitled “Five Year Review Report for the Aberdeen Area, dated September 2003”. The report was prepared to address the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) Section 121 (c) Five Year Review requirements. EPA has reviewed this report and compared it to the OSWER Directive 9355.7-03B-P, Comprehensive Five Year Review Guidance (EPA, June 2001). The report generally meets the intent of EPA’s Five Year Review Guidance Document. EPA concurs conditionally with the Five Year review for the Aberdeen Proving Ground - Aberdeen Area NPL Site, assuming that all short term appropriate land use controls will be applied by the Army. The protectiveness of many of the remedies strongly depends on the proper application of land use controls. There is still an unresolved dispute between EPA and the Army regarding EPA’s post ROD authority as it applies to land use controls. Since there is not a final all-encompassing land use control document which obligates Aberdeen Proving Ground to enforce all needed and appropriate land use controls at this site, any protectiveness statement is dependent on the Army’s vigilance and application of appropriate controls. It should also be clear to the public the Aberdeen Proving Ground Aberdeen Area is an Army “Mega Site” with environmental problems that have accumulated over sixty years, from 1918 to 1980 when the RCRA and Superfund Acts were passed. At the Aberdeen Area, only Michaelsville Landfill was actually on the NPL listing document. However, the Aberdeen Proving Ground Federal Facilities Agreement requires APG to address the many environmental problems in the Aberdeen Area as if they were on the NPL. The produces the unusual result, that although, Michaelsville Landfill has been construction completed and there is a Final Completion Report done, work continues to go on with remedial investigations, feasibility studies, RODS, RD/ RAs and other environmental work on the many Solid Waste Management Units identified in the RCRA Facilities Assessment. These areas are being tracked as DSERTS by the Army. Because Michaelsville Landfill was completed, the Army asked EPA to delete the site from the NPL and complete all the other numerous DSERTS under the FFA. Due to a large VOC plume which contaminated Harford County Municipal wells and the discovery of perchlorate in the City of Aberdeen water supply, EPA Region 3 decided to delay delisting until these serious issues are resolved, rather than diverting resources to delisting. Celebrating 25 Years of Environmental Progress 2 The Aberdeen Area peninsula has eroded substantially over the last one hundred years and this erosion periodically exposes munitions, bottles of chemicals and other problems. The Army has taken actions to stabilize some seriously eroded shorelines, but much unprotected shoreline exists. To date, much of facility boundary has not been surveyed to determine if there are munitions outside the facility fenceline. APG is beginning to address this issue, but it is years from being completed. Unlike a typical NPL facility that may have one major waste unit and a few smaller contaminated areas, the Aberdeen Area has a very large number of contaminated areas in various stages of investigation, design, construction of remedial actions. The Aberdeen Area of Aberdeen Proving Ground will take years of work until all major chemical and ordnance hazards will be addressed, and during this time, land use controls will be needed to protect the public and military personnel. EPA also has little knowledge of how Army personnel use the various areas at Aberdeen, which is still an active firing range, making assessment of the adequacy of land use controls difficult, at least as they pertain to military personnel . In summary, EPA concurs with the Five Year Review, but it is the Army’s responsibility to maintain adequate land use controls to protect the public, the environment and military personnel, until a final land use control document is in place for all areas of contamination. If you have any questions, please contact Frank Vavra at (215) 814-3221. Sincerely, Abraham Ferdas, Director Hazardous Sites Cleanup Division cc. Karl Kalbacher, MDE Christine Grochowski, APGSCC Paul Leonard, EPA Kenneth P. Stachiw, APG Celebrating 25 Years of Environmental Progress Aberdeen Proving Ground Aberdeen Area Five-Year Review September 2003 Prepared by: Reviewed by: KENNETH P. STACHIW Environmental Engineer Chief, Environmental Conservation and Restoration Division j, 23, =mx q ‘(Date) Concurred by: Approving Official: - ;fGl-;~~f~L.- Director, Safety, Health and Environment xputy installatidn Commander / L&-k c-3 0 tj OCT 2003 (Date) (Date) FIVE-YEARREvmwsuMMAR Y FORM Sitename (fromWasteLAN): Aberdeen Provinq Ground/Aberdeen Area (Michaelsville Landfill, Western Boundary Study Area, Other Aberdeen Areas, Bush River Bomb Disposal Site, and Abbey Point Shoreline Piles 3 through 7) EPAID (ffom WesteLAN): MD3210021355 Region: -03 State: -MD 1 City/County: Aberdeen/Harford Remediatlon status (choose all that apply): q Under Construction J Operating J Complete Multiple OUs?* J YES o NO Construction completion date: Various Has site been put into reuse? 4 YES J No Authorname: Naren Desai Authortitle: Project Officer AuthorAffiliatIon: Department of Army Review period? Various Date(s) of site inspection: Various Type of review: (Statutory 0 Policy (o Post-SARA o Pre-SARA q NPL-Removal only D Non-NPL Remedial Action Site q NPL State/Tribe-lead o Regional Discretion) Review number: J 1 (first) o 2 (second) o 3 (third) o Other (specify) Triggering action: J Actual RA Onsite Construction western Boundary o Actual RA Start Study Area, Bush River Bomb Disposal Site. Abbey q Previous Five -Year Review Report Point Shoreline Piles 3 throuah 7) J Construction Completion (Michaelsville Landfill) .f Other (specify) APG request [Other Aberdeen Areas) Triggering action date (From WasteLAN): Various Due date (five-years after triggering action date): October 2 0 0 3 *rOU refers to operable unit.] **[Review period should correspond to the actual start and end dates of the five-year review in WasteLAN.] FIVE-YEAR REVIEW SUMMARY FORM Deficiencies: There have been no deficiencies identified as a result of these five-year reviews, Recommendations and Follow-Up Actions: Michaelsville Landfill OU 1 - Michaelsville Landfill: Continuation of operation and maintenance (O&M) to maintain landfill cap and cover integrity, proper operation of the runoff collection system, and proper operation of landfill gas venting system. OU 2 - Michaelsville Landfill Groundwater: Long-term monitoring program should continue as outlined in the Operable Unit (OU) 2 Record of Decision (ROD) and monitoring plan. The long-term monitoring program should report the occurrence and location of contaminants not previously identified. Three rounds of groundwater sampling and analysis have been completed at this area since the initiation of the monitoring plan. The Third Monitoring Report will present recommendations for future monitoring. Western Boundary Study Area (WBSA) OU 1 - Groundwater in the Southwestern two-thirds of the Western Boundary Study Area (WBSA) near the Harford County Production (HCP) wells: In 1991, trichloroethene (TCE) was detected in two HCP wells (HCP-5 and HCP-6) located at the Perryman well field. Aberdeen Proving Ground (APG) constructed an interim Granular Activated Carbon (GAC) treatment system to treat the groundwater from these two wells. A new GAC plant has been constructed at Harford County’s Perryman facility and began operation in 2003. Components from the interim GAC plant were utilized during the construction of the new GAC plant. The new GAC treatment plant treats water from all of the HCP wells (HCP-1, -2, -4, -5, -6, -8, and -9). Groundwater monitoring has been conducted and a review report will be prepared five years after commencement of remedial action to ensure that the selected remedy continues to provide adequate protection of human health OU 2 - Groundwater located in the northwestern portion of the WBSA: There has been no remedial activity or ROD issued for OU2. Low levels of volatile organic compounds (VOCs) and methyl tertiary butyl ether (MTBE) have been reported in groundwater samples obtained from OU2. In addition, perchlorate was detected in groundwater samples obtained from wells, geoprobes and several CAP wells. A draft Remedial Investigation (RI) for OU2 has been submitted and an additional remedial investigation is ongoing. Four underground storage tanks (USTs) were removed from the Block 4700 area in 1990 and 1995 OU 3 - Contains all other media in the WBSA OU 1 and OU 2 areas, including soil, sediment. and surface water: A soil removal action was also performed at the Aberdeen Fire Training Area (AFTA) between 1992 and 1994. In order to address detected soil contamination, three excavation